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 3. Trust and Safety
 4. Privacy Policy


FLIP PRIVACY POLICY

Last updated: December 21, 2022

 

Your privacy is important to us.

 

This Privacy Policy governs how Flipgrid, Inc., a Microsoft subsidiary, (“Flip,”
“we,” “our,” or “us”) collects, uses, and shares personal information about
Leads, Members, and Guests, as those roles are defined below (collectively,
“Users” or “you”). This Privacy Policy applies when you use our website at
Flip.com, the Flip mobile app, and any associated services (collectively, the
“Service”). 

 

We may make changes to this Privacy Policy from time to time. If we make
changes, we will notify you by revising the “Last Updated” date above, and, in
some cases, we may provide you with additional notice (such as adding a
statement to our website or sending you a notification). We encourage you to
review this Privacy Policy regularly to stay informed about our information
practices and the choices available to you. 


“You” may be a: 

 

Lead 

A “Lead” initiates and manages Groups and Topics and manages and sets
permissions for Member and Guest videos and text within those Group(s) and
Topics. Leads using the Service with an email address provided by their
affiliated organization, such as an educational institution or organization or
other educational business (each, a “School”) are referred to as “School
Leads.” Except as otherwise provided herein, any User who is not a Child or
Student Member, defined below, may use Services as a Lead. 


 

Go here to learn more about Getting Started as a Lead. Learn more about Topics
and Groups here. 

 

Co-Lead 


A “Co-Lead” helps Leads manage their Group(s) by adding students, creating, and
managing Topic(s), and providing student feedback. Co-Leads do not have the
ability to invite other Co-Leads to the Group or delete any user generated
content. Co-Leads using the Service with an email address provided by their
School are referred to as “School Co-Leads.” 

 

Go here to learn more about Getting Started as a Co-Lead. Learn more about
Topics and Groups here. 

 

Member 


A “Member” is invited to participate in Groups and Topics via a join code
provided by a Lead, such as a student invited by their school teacher (a
“Student Member”). Members can create and manage their own videos and text
within a Group or Topic.

Go here to learn more about Getting Started as a Member. 

 

Guest

A Guest is invited to participate in Topics via a join code and guest password
provided by a Lead. Guests can create and manage their own videos and text
within a Topic. 
 
Go here to learn more about Getting Started as a Guest.

 

User 

As used in this Privacy Policy, a “User” is any user of the Service, including
Leads, Co-Leads, Members, and Guests.


1. INFORMATION FLIP COLLECTS

Flip collects personal information about Users as described below.

 

 1.1 Directly Collected Information 

 

 a) Information Collected from Leads and Co Leads

 

When a Lead creates an account on the Service, we may ask for certain
information, such as the Lead’s first name, last name, email address,
password, date of birth, community information, and country. Leads may provide
us with the name and email address of each Member and Guest they invite to use
the Service. 

 

School Leads provide consent for the collection of Student Member personal
information as discussed in Section 8 of this Privacy Policy, below. 

 

 b) Information Collected from All Users

 

We collect information from Users when you post content on the Service, such
as Topics, text, videos, and other material. This information may include first
name, last name, date of birth, email address, geographic location, and audio
and image included within a video. Your Lead may permit you to access certain
features on the Service. If you choose to use these features, additional
information may be collected. For example, use of an augmented reality
camera effect in your videos may use object recognition to detect different
areas of your face (this feature does not recognize specific individuals and the
information used to provide you with this effect does not leave your device). 

 

We also collect information from Users when you provide us with feedback
or otherwise communicate with us, such as when you contact us via email or by
submitting the contact form on our Service.

 

1.2 Automatically Collected Information

 

When you access or use our Service, we automatically collect certain
information, including:

 

 * Device and Usage Information: When a User uses the Service, some information
   may be automatically collected to help us understand how the Service is being
   used and how to improve the Service. For example, we may collect device type,
   the device identifier (UDID), date/time stamps, browser type, operating
   system, Internet Protocol (IP) address, Internet service provider (ISP),
   referring/exit pages, clickstream data, and domain name.

 * Information Collected by Cookies and Similar Technologies: As described in
   the Cookies and Analytics section below, we (and our service
   providers) use tracking technologies, such as cookies (small text files
   placed on your device) and web beacons to collect information about you. For
   more information about cookies and how to disable them, see the Your Choices
   section below. 

 

1.3 Information Collected from Other Sources

 

We may also collect information about you from other sources. For example, if
a Member or Lead uses a third-party login service (such as Google) to access or
sign up for the Service, we may collect information about the Member or Lead
from that third-party service, including their first name, last name, email
address, country, date of birth and other information.


2. USE OF PERSONAL INFORMATION

We use the information we collect to provide our Service to all Users, including
for the following purposes: 

 

 * To provide, maintain, and improve the Service, including updating, securing,
   troubleshooting, and providing support;

 * To authenticate Leads and Members who access the Service using a third-party
   account, such as their Microsoft, Apple or Google account;

 * To improve and develop the Service;

 * To respond to User comments and questions and provide customer service;

 * To communicate with Users, other than Student Members, about Microsoft or
   Flip products, services, and events, new Flip features and other news and
   information we think will interest Leads (see the Your Choices section below
   for information about how to opt out of these communications at any time).

 * To send Users information including confirmations, technical notices,
   updates, security alerts, and support and administrative messages.

 * To monitor and analyze trends, usage, and activities in connection with
   the Service. Information about Members used for this purpose is de-identified
   or aggregated so that it cannot reasonably be used to identify any individual
   Member. 

 * To detect, investigate, and prevent security incidents and other malicious,
   deceptive, fraudulent, or illegal activity and protect the rights and
   property of Flip and others.

 * To debug to identify and repair errors in our Service. 

 * To facilitate the creation and management of accounts on our Service.

 * To comply with our legal and financial obligations.

 * To create de-identified, anonymized, or aggregated information. 

 * For any other purpose described to you at the time information is collected
   or with your permission.

 

When you use the Service, Flip does not use your personal information to market
or advertise non-Microsoft products or services to you. When you use the
Service, Flip also does not use your personal information to track and target
advertisements on third-party websites or services.


3. INFORMATION WE SHARE

Flip does not sell User personal information. We share personal information in
the following circumstances or as otherwise described in this Privacy Policy:  

 

 * When you use the Service, your personal information and content may be shared
   with other Users who you interact with on the Service. 

 * We share User personal information with vendors, consultants, and
   other third-party service providers who need access to such information
   to perform services for us, such as companies that assist us with web hosting
   and customer service. View service providers. 

 * We may share User personal information if we believe that disclosure is in
   accordance with, or required by, any applicable law or legal process,
   including lawful requests by public authorities to meet national security or
   law enforcement requirements. We may share personal information if we believe
   that your actions are inconsistent with our agreements, policies, or terms of
   use, if we believe that you have violated the law, or if we believe it is
   necessary to protect the rights, property, and safety of Flip, our employees
   and agents, our Users, the public, or others. 

 * We share personal information with our lawyers and other professional
   advisors where necessary to obtain advice or otherwise protect and manage our
   business interests. 

 * We may disclose or transfer your personal information in connection with, or
   during negotiations concerning, any sale, merger, bankruptcy, sale of assets,
   financing, acquisition, or reorganization, in whole or in part, of our
   company. 

 * We may share personal information between and among Flip and our current and
   future parents, affiliates, subsidiaries, and other companies under common
   control and ownership. 

 


4. INFORMATION USERS SHARE

4.1 Sharing to other Users

 

When you share content to a Group or Topic, that content is accessible
by any User who has permission to access the Group or Topic, subject to
the Lead’s ability to deactivate, moderate, or hide Groups, Topics, and
the content within them. The Lead, not Flip, sets the Group or Topic access
permissions and privacy settings, including access permissions
for content within a Group or Topic. 

 

 4.2 Sharing to Recipients Outside the Service  

 

You can share the content you submit to a Group or Topic with your friends or
others who do not use the Service via a link (a “Content URL”). If the recipient
of a Content URL sends the Content URL to other people, those other people will
also be able to access your content on the Service. 

 

Depending on the permissions set by your Group or Topic Lead, you may also be
able to invite your friends or others who do not use the Service to access a
Group or Topic via a link (a “Group/Topic URL”). Leads, not Flip, set the access
permissions and privacy settings that determine whether a Group/Topic
URL will work for recipients. 

 

Flip does not, and cannot, control how Users share Content URLs or Group/Topic
URLS outside the Service, how Leads set Group/Topic URL access permissions, or
how recipients of Content URLs or Group/Topic URLs will view, use, or reshare
such URLs and the content made accessible through them. 


5. THIRD-PARTY SITES AND SERVICES

The Service may link to third-party sites, services, plug-ins, and
applications that are not operated or controlled by Flip (each a “Third-Party
Service”). Leads, and not Flip, determine whether such Third-Party Services are
accessible to Users on their Groups and Topics. Third-Party Services are
governed by their respective privacy policies. This Privacy Policy does not
apply to such Third-Party Services, and we cannot take responsibility for the
content, privacy policies or practices of third-party services.


6. ANALYTICS

We use cookies and similar technologies to collect information about your use of
the Service in order to analyze and track data and determine the popularity of
certain content on our Service. Cookies are small data files stored on your hard
drive or in device memory that help us provide and improve the Service and your
experience, collect data about the Service and how it is used, and to share
information about Flip and its features and functionalities to Leads. For
example, cookies allow you to log in to secure areas of the Service and help the
content of the pages load quickly. We use cookies to provide you with a more
personal, useful, and interactive experience with our Service. We also use web
beacons (also known as “pixel tags” or “clear GIFs”) to help deliver cookies and
gather usage and performance data. 

 

In addition to the cookies we set, we allow other third-parties to provide
analytics services on our behalf. These third-parties can set cookies when
you use the Service to collect information about you. For example:

 

 * Companies we hire to provide services that help us offer our Service, such as
   site analytics providers, may place cookies when you visit our sites.

 * Companies that deliver content, such as videos a Lead links to or embeds,
   place cookies on their own. These companies use the data they process in
   accordance with their privacy policies, which may enable these companies to
   collect and combine information about your activities across websites, apps,
   or online services.

 

Each User has a variety of tools to control cookies, web beacons, and similar
technologies, including browser controls to block and delete cookies and
controls from some third-party analytics service providers to opt out of data
collection through web beacons and similar technologies. User browser settings
and other choices may impact the functionality of the Service. 


7. INFORMATION CHOICES AND CHANGES

7.1 Personal Information and User Content 

 

Users may opt out of providing personal information to the Service at any time
by ceasing to use the application. Users (and their parents, if applicable) may
also request deletion of their personal information, including content, by going
to Flip Help or, in some cases, contacting the relevant Group/Topic Lead. We may
ask you for certain information about yourself or about your content to validate
your request. If we cannot validate your request, we may not be able to remove
the content. Learn more about the choices Users have with respect to access and
deletion of their information here. 

 

If you request deletion of your account or content, please note that we may
still retain certain information as required by law or for our legitimate
business purposes as outlined in Section 10 of this Policy.

 

7.2 Communications Preferences

 

We may send Leads emails regarding events, news, and other topics, as described
in the Use of Personal Information section above. Leads can opt out of receiving
such emails by following the instructions provided in those emails. Note that if
a Lead opts out of such emails, we may still send them operational emails that
pertain to the Lead’s account and notifications regarding our Service.


8. CHILDREN'S PRIVACY

This section of the Privacy Policy applies to information we collect from Users
under the age of 13 or the age where Parental consent is required for use of the
Service under applicable law (individually, a “Child,” and collectively,
“Children”). With consent from a parent or legal guardian (a “Parent”) obtained
by their School Lead, Children can use the Service as Student Members. In
certain cases, and only after providing Parental consent in compliance with
applicable law, Children can use the Service as Leads. Please contact Flip at
flipsupport@Microsoft.com if you have further questions. 

 

If we learn that we have collected a Child’s personal information
without legally required Parental consent, we will take steps to delete the
information as soon as possible. Parents who believe that their Child has
submitted personal information to us and would like to have it deleted may
contact us at Flip Help. 

 

 8.1 Collection, Use and Disclosure of Children’s Information 

 

Under the United States Children’s Online Privacy Protection Act (“COPPA”),
verifiable Parental consent is needed to collect, use, or disclose personal
information (e.g., full name and email address) from each User under 13 years
old.

 

 a) Information Collected from Children. We obtain verifiable Parental consent
before collecting, using, or disclosing information from a Child, including as
described in Section 8.2 for Student Members. We collect the same types of
personal information from Children as we do from other Members, as described in
Section 1 above. We will not knowingly require any Child to disclose more
information than is reasonably needed to participate in the Service. 

 

b) Use and Sharing of Children’s Information. Once we obtain verifiable Parental
consent, we may use and share personal information collected from Children for
the same purposes applicable to other Members, except as otherwise described
in Sections 2 through 6 above. As with other Users, we do not sell Children’s
personal information or use Children’s personal information to market or
advertise to Children, nor do we permit third-parties to do so. 

 

c) As described in Section 4.1, content Children post to Groups and Topics may
be visible to other Users of the Service. As described in Section
4.2, content Children post to the Service may also be accessible to individuals
outside the Service who receive a Content URL and/or Group/Topic URL containing
a Child’s content. We encourage Parents to monitor their Children’s use of the
Service, including the content and personal information they submit. Flip is not
able to control or monitor all personal information or content Children
may submit to the Service, nor what Users or recipients of a Content URL or
Group/Topic URL may ultimately do with any information or content they have
access to from the Service. 

 

d) Parental Rights. Parents have certain rights with respect to our collection,
use, retention, and disclosure of their Child’s information. This includes the
right to review, update, or delete personal information about their Child, as
well as to prohibit our sharing of personal information about their Child with
certain third-parties. Parents can exercise these rights by contacting their
Child’s School Lead or by sending requests directly to us at Flip Help. Please
note that if a Parent requests deletion of his/her Child’s personal information
or content, we may still retain certain information as required by law or for
our legitimate business purposes as outlined in Section 10. Children and their
Parents can learn more about the choices Users have with respect to their
information here. 

 

8.2 Notice to Schools and Student Members

 

In accordance with COPPA, a teacher, such as a School Lead, may act as the agent
of the Parent of a student and provide consent on behalf of the Parent for
Flip’s collection, use, and disclosure of the student’s personal information. As
such, by enrolling a Student Member under 13 to use the Service, the
School Lead provides such consent to us and agrees that the Student Member’s
activities while on the Service are subject to our Terms, including but not
limited to our Code of Conduct. Please see the Parent Consent Form for
guidelines on how teachers and Schools may provide consent on behalf of Parents.

 

This Privacy Policy does not govern any School’s collection, use, or disclosure
of a Student Member’s personal information through the Service, and we are not
responsible for any such collection, use, or disclosure. 


9. INFORMATION SECURITY

We use security technologies and procedures to help protect your personal
information. While we take efforts to protect your personal information, please
remember that no transmission of information on the Internet is 100% secure,
and we cannot guarantee or be responsible for absolute security of your
information. You can learn more about our information security practices here. 


10. DATA RETENTION

We store the information we collect for as long as you have an account (if you
are a Lead), or for up to 30 days in our archives when you ask for data to
be deleted. Additionally, we may retain User information to resolve disputes,
enforce our policies, and to comply with the law. 


11. PERSONAL INFORMATION TRANSFERRED FROM THE EUROPEAN ECONOMIC AREA OR
SWITZERLAND

Personal information collected by Flip may be stored and processed in your
region, in the United States, and in any other country where
Flip or our affiliates, or service providers operate facilities. We take steps
to ensure that the personal information we collect under this privacy policy is
processed according to the provisions of this policy and the requirements of
applicable law wherever the data is located. We transfer personal data from the
European Economic Area, the United Kingdom, and Switzerland to other countries,
some of which have not yet been determined by the European Commission to have an
adequate level of data protection. For example, their laws may not guarantee you
the same rights, or there may not be a privacy supervisory authority there
that is capable of addressing your complaints. When we engage in such transfers,
we use a variety of legal mechanisms.


12. ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (EEA), the United Kingdom, or
Switzerland, you have certain rights and protections under the law regarding the
processing of your personal information, and this section applies to you.

 

12.1 Legal Basis for Processing

 

 When we process your personal information, we will do so in reliance on the
following lawful bases:

 

 * To perform our responsibilities under our contract with you (e.g., providing
   the products and services you requested). 

 * When we have a legitimate interest in processing your personal data to
   operate our business or protect our interests (e.g., to provide, maintain,
   and improve our products and services, conduct data analytics, and
   communicate with you).

 * To comply with our legal obligations (e.g., to maintain a record of
   your consents and track those who have opted out of marketing
   communications).

 * When we have your consent to do so (e.g., when you opt in to receive
   marketing communications from us). When consent is the legal basis for our
   processing your personal information, you may withdraw such consent at any
   time.

 

12.2 Data Retention

 

Please refer to Section 10 of this Privacy Policy to learn about our retention
periods for personal information we collect.

 

 12.3 Data Subject Requests

 

Subject to certain limitations, you have the right to request access to the
personal information we hold about you and to receive your data in a portable
format, the right to ask that your personal information be corrected or erased,
and the right to object to, or request that we restrict, certain processing. If
you would like to exercise any of these rights, please contact us at Flip Help. 

 

12.4 Questions or Complaints

 

If you have a concern about our processing of personal information that we are
not able to resolve, you have the right to lodge a complaint with the Data
Protection Authority where you reside. Contact details for your Data Protection
Authority can be found using the links below:

 

 For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

 

 For individuals in the UK: https://ico.org.uk/global/contact-us/

 

 For individuals in
Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html


13. RIGHTS OF CALIFORNIA RESIDENTS

13.1 California Consumer Privacy Act

 

If you are a California resident, we process your personal information in
accordance with the California Consumer Privacy Act (CCPA). If you are a
California resident, this section may apply to you and supplements our Privacy
Policy.

 

Sale. We do not sell your personal information. We do not knowingly sell
personal information about consumers under the age of 16.

 

Rights. Subject to certain limitations, you have the right
to: (i) request to know more about the categories and specific pieces
of personal information we collect, use, and disclose; (ii) correct inaccuracies
in your personal information; (iii) request deletion of your personal
information; (iv) opt out of any “sales” of your personal information that may
be occurring; (v) limit the use and disclosure of your sensitive personal
information; and (vi) not be discriminated against for exercising these rights. 

 

Exercising Your Rights. You may exercise your rights by contacting us at
flipsupport@microsoft.com,  filling out the form at Flip Help, or by taking the
steps described here. If you contact us to make a request to exercise your
rights, we may ask for additional information to validate your identity before
honoring the request.

 

You may make these requests through an authorized agent. If you use an
authorized agent and they do not provide a valid power of attorney, we may ask
the authorized agent to provide proof that you gave the agent signed permission
to submit the request to exercise rights on your behalf. We may also request
information from you to verify your own identity directly with us or confirm to
us that you otherwise provided the authorized agent permission to submit the
request. If you are an authorized agent seeking to make a request, please send
an email to flipsupport@microsoft.com.

 

If you wish to appeal our response to a consumer rights request, please contact
us at flipsupport@microsoft.com, or make an inquiry at Flip Help.

 

 We will not discriminate against you if you exercise your CCPA rights. 

 

 Personal Information Processing. In the preceding 12 months, we have collected
the following categories of personal information: personal identifiers,
information subject to Cal. Civ. Code § 1798.80(e), characteristics of protected
classifications under California or U.S. law, commercial information, Internet
or other electronic network activity information, professional or
employment-related information, audio, electronic, visual or similar information
and inferences drawn about you and other categories of personal information that
relate to, describe or are reasonably capable of being associated with you. 

 

For details about the precise data points we collect and the categories of
sources of such collection, please see the Information Flip Collects section
above. We collect personal information for the business and commercial purposes
described in the Use of Personal Information section above. In the preceding 12
months, we have disclosed the following categories of personal information for
business or commercial purposes to the following categories of recipients: 

 

Category of Personal Information Categories of Recipients

Identifiers


 

 

Customer support partners, Internet service providers, operating systems and
platforms, other Users, online and digital safety partners, cloud service
providers, technical maintenance, and system security providers  Commercial
Information Customer support partners, online and digital safety partners, cloud
service providers Characteristics of Protected Classifications under state or
federal law, such as age  Other users, customer support partners  Internet
or other electronic network activity Internet service providers, operating
systems and platforms, cloud service providers, online and digital safety
partners, technical maintenance, and system security providers Geolocation data
Internet service providers, operating systems, and platforms  Professional or
employment-related information Customer support partners, other Users
Audio, electronic, visual, or similar information Customer support partners,
other Users  Inferences Customer support partners, online and digital safety
partners, cloud service providers

 

13.2 How We Respond to Do Not Track Signals

 

We do not currently respond to "do not track" signals or other mechanisms that
might enable consumers to opt out of tracking on our website.


14. FLIP LENSES PRIVACY NOTICE

When you use the Flip Camera, you can choose to enhance your video and audio
with Flip Lenses. For example, Flip Lenses can show you wearing a party hat,
have your backdrop appear as though you are on the moon, help you learn sign
language, or alter your voice into a chipmunk-style high pitch. Depending on
which Flip Lens you choose, your video and audio may be processed to extract
information about your voice and about the location of different areas on your
face and hands (collectively, “Extracted Data”).

 

Some of this Extracted Data may be considered biometric data in certain
jurisdictions. None of this Extracted Data is used to personally identify you.
Extracted Data is used for the sole purpose of providing Flip Lenses to you.
Extracted Data is processed for the duration of the session on your device only
then deleted. The Extracted Data is not sent to Flip or any third party. 

 

Processing of Extracted Data is subject to this notice only. For information on
how Flip handles your video, audio and any personal information see the Use of
Personal Information section in the Flip Privacy Policy. 


15. CONTACT INFORMATION

If you have any questions about this Privacy Policy or wish to contact us,
please contact us at Flip Help.

 

You can reach Flip by mail or phone at:

 

Flipgrid, Inc.

Microsoft Corporation

One Microsoft Way

Redmond, Washington 98052, USA

Telephone: +1 (425) 882 8080.

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